Transparent information about products and services

One of the fundamental goals is to find the right match between the offer and the needs of every client. The Bank strives to ensure that offers / services are presented after an in-depth needs analysis and meet the expectations of clients, while being fully comprehensible and transparent to them. In the process of opening an account and initiating a relationship with a client, employees use aids that are prepared in an attractive format, are highly transparent and feature clear and comprehensible language for the purpose of communication. These materials have been developed on the basis of in-depth research and interviews with clients and are used to diagnose client needs correctly and optimally and adapt the sales pitch accordingly.

Every person visiting the website may obtain detailed information about the offering and the services recommended by the Bank depending on the client’s current needs. There is also a hotline available to clients 24 hours a day and 7 days a week.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of personal accounts, nor were there any consumer boycotts.

Information on savings products in the form of a set of the most important attributes or in more detail, while paying attention to the constituent elements of given products may be found on the Bank’s website, may be obtained in any branch, through the hotline or in electronic banking channels. The Bank regularly improves the method of presenting product information, especially in its remote channels. Employees are trained in such a manner so as to be able to convey a given scope of information on every product, including a uniform information document on the scope of savings products in which one can easily and readily compare the attributes of all products. The Bank also analyses clients’ questions and complaints to eliminate their causes.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of savings accounts, nor were there any consumer boycotts.

Marketing materials prepared by the Bank comply with the laws and regulations applicable to this area, including the Canon of Best Financial Market Practices and the guidelines laid down by the Polish Financial Supervision Authority. Bank Millennium tracks and modifies materials on an ongoing basis to meet the recommendations of the Polish Financial Supervision Authority. Trade publications are subject to review by legal and compliance teams, among others. These units are responsible for ensuring that materials are in compliance with the law and with the guidelines of supervisory authorities.

In addition, prior to purchasing an investment product, clients fill out an Investment Survey. Its purpose, among other things, is to verify a client’s knowledge and experience regarding financial instruments and services and check whether a client belongs to the target group of recipients of a specific instrument or service.

Based on the responses provided, the client receives the Investment Survey result with information about the financial instruments and services for which the client is part of the target group and which of them are suitable or unsuitable to that client. In accordance with prevailing laws, the Bank does not apply limitations on the sales of investment products to specific groups of people.

Any proposal to start offering a new product is commented upon at several levels; opinions are issued among others by the risk, compliance and legal units. Participation of those entities in the opining process allows the Bank to assess whether:

• the identified material risks and their mitigation methods arising in connection with the launch or change of a product/service are permissible,
• the proposed product/service complies with the requirements concerning: provision of relevant information to potential clients before the agreement is signed, fulfilment of information obligations during the provision of the financial service, identification of conflicts of interest in order to take prior measures to prevent their occurrence, reliability and completeness of information provided,
• the proposed product/service complies with the applicable law and assessment of legal risks.

The Bank complies with the requirements of the MiFID 2 directive (Markets in Financial Instruments Directive). In accordance with the requirements of MiFID 2, the Bank, by offering investment services, is obligated before the purchase of a product, in particular:

• to classify the client to one of the three categories of investors,
• to carry out an Investment Survey, which is designed to test the client’s knowledge and experience with individual financial instruments or services, as well as to check whether the client belongs to the target group of recipients of a specific financial instrument or service,
• to provide reliable information that is not misleading about products and risks associated with investments in those products as well as all the related costs,
• to develop a policy of acting in accordance with the best interests of its clients and a policy to prevent the conflict of interest and inform the client about these policies.

To ensure the best possible protection level to its customers, the Bank applies some MiFID 2 guidelines also to insurance and investment products, even though this is not legally required.

All the marketing publications prepared by the Bank describe, among others, the risks associated with investments and sample scenarios related to a given financial instrument or product. Clients are presented with complete and reliable information on the Bank’s own products and products distributed by the Bank, including their issuers and the terms of the complaint process. Information on services rendered, agreements and other bank documents and letters sent to clients are drafted in a precise, comprehensible and transparent manner.

[GRI 417-1] Any information materials concerning investment products offered by Bank Millennium provide relevant information on the risk associated with investment, legal disclaimers as well as the sites where additional information on the funds (for example on funds or selected financial data) is published.

If a client wants to purchase a product the Bank considers to be unsuitable or if the Bank does not have the ability to assess a given product, the Bank advises the client thereof by issuing a warning to the client during the process of submitting the order. The client also receives this warning on the order form. The client is obligated to review the warning and if the client still wants to buy the product, the client is obligated to accept it. Similar rules apply to the target group evaluation process.

Before starting to offer investment products, the relationship manager should have at least twelve months of professional experience in this area and have passed a product knowledge test. Each relationship manager must also undergo mandatory training on the MiFID 2 and a product training in the e-learning form. The product training describes detailed characteristics of a given product and clearly points to the risks associated with investments in a given product or financial instrument. If the relationship manager does not have the required level of experience or knowledge, he/she works under the supervision of the so-called authorized employee who regularly verifies his/her work.

If the law or internal regulations governing investment products change, e-learning refresher training is made available to relationship managers. As a result, the employees have adequate and current knowledge of the investment products offered. Additionally, relationship managers take advantage of regular market and product conference calls. The Bank’s employees also have permanent access to current product presentations.

[GRI 419-1] In 2021 no penalties were imposed on the Bank for non-compliance, nor were there any consumer boycotts concerning the investment products offered by the Bank.

A client filing a loan application will receive full information about the product and the associated risks from an employee at each stage of the process. In 2021 the Bank delivered preliminary online training and webinars on a major scale pertaining to product structure and the lending process to remind them in a clear, accurate and transparent manner on how to convey product details to clients and select the best offer for them. Approximately 3,500 mortgage experts were trained in the brokerage network in 2021. Preliminary and typical product training sessions were held. The webinar training sessions aimed, among other things, to promote innovative solutions relating to processes and products among the experts cooperating with the Bank. In 2021 nearly 600 employees of the Bank Millennium branches underwent specialist training on mortgage products on different levels of sophistication in preparations for “Mortgage Certification”. During the first round of certification more than 100 managers in the Bank’s branches tested their knowledge in the certification exam and their mortgage skills confirmed by their sales results, thereby obtaining a Mortgage Certificate.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of mortgage products being currently offered, nor were there any consumer boycotts. The legal issues connected with Swiss franc mortgage loans are described on the Settlements and other solutions for foreign currency loan borrowers.

Before the purchase of a product, the Bank investigates the client’s needs and helps to establish the client’s financial standing and thus adjust the manner of communication and offer a suitable product. The risk of over-indebtedness and household budget mismanagement is minimized owing to advanced methods of assessing clients’ creditworthiness and capabilities used by the Bank. The Bank may offer to its clients the opportunity to consolidate the debt repaid to other lenders, which often allows them to reduce their monthly credit charges in the household budget and improve their financial security.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of consumer loans, nor were there any consumer boycotts.

Information regarding insurance products is presented by the Bank in a manner customized to the sales channel for a given product, orally or at the various stages of the sales process in remote channels. This information is also set forth in the insurance documentation and/or banking documentation of the bank product to which the insurance is offered. The Bank takes into consideration the aspect of customizing insurance to clients’ needs and expectations in the process of offering insurance.

Insurance documentation contains standardized specific provisions regarding insurance stemming from the regulations of law and the guidelines set forth in Recommendation U concerning best practices in bancassurance and the Insurance Distribution Act that provide for transparently presenting products to clients.

The Bank employs the rules of ethical sales of products by providing for standards consistent with the guidelines set forth in Recommendation U concerning best practices in bancassurance and the Insurance Distribution Act.

The Bank educates its employees to procure the appropriate level of quality in the process of selling insurance products. On top of product training sessions ending with an exam to confer authorization to commence the sales of insurance, Bank employees go through annual professional training sessions to enhance their competences systematically in terms of performing tasks involving insurance intermediation services. Besides legal issues much attention during training sessions is devoted to the general rules and practical aspects of distribution activity.

[GRI 419-1] In 2021 no penalties were imposed on the Bank in terms of insurance products, nor were there any consumer boycotts.